State v. Tafuna, 286 P.3d 340

Tafuna attended a Halloween party; his accomplice Valdez rifled through a resident’s belongings and Tafuna pulled a knife as they tried to leave with stolen goods.
Witnesses observed the incident; police later found Tafuna’s leather coat with a wallet containing multiple identification cards, though the stipulation that such IDs would not be mentioned was agreed pretrial.
Tafuna was charged with aggravated robbery and a weapons offense and tried by jury in October 2008.
A juror had briefly spoken with State witnesses outside the courtroom; the district court conducted an in-chambers inquiry and allowed the juror to remain, with later deliberations held.
During trial, a detective testified that Tafuna had received various IDs from a wallet found with the coat, which violated a pretrial stipulation; the State later withdrew the coat and its contents, and the court instructed the jury to disregard related testimony.
Tafuna sought a mistrial after the identification-card reference; the district court denied, and Tafuna was convicted of aggravated robbery on the jury’s verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror contact with witnesses affected jury impartiality	Tafuna argues contact violated fairness and created presumption of prejudice.	State contends invited error and waivers render issue non-reversible.	Waived by defense counsel; no reversal.
Mistrial due to identification-card testimony	Reference violated stipulation and implied identity theft evidence.	Single, fleeting reference; insufficient to prejudice; no abuse of discretion.	Not an abuse of discretion; mistrial denied.

State v. Allen, 2005 UT 11, 108 P.3d 730 (Utah (Supreme Court) 2005) (presumption of prejudice from unauthorized juror contact; prosecution burden to rebut)
Logan City v. Carlsen, 799 P.2d 224 (Utah Ct. App. 1990) (rigorous approach to juror-contact issues)
State v. Pike, 712 P.2d 277 (Utah 1985) (unwanted juror contact creates presumption of prejudice; burden on State to rebut)